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DALE v. COMMISSIONER

Docket No. 11212-78.

45 T.C.M. 80 (1982)

T.C. Memo. 1982-654

Robert Dale v. Commissioner.

United States Tax Court.

Filed November 15, 1982.

Attorney(s) appearing for the Case

George W. Reynolds, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned pursuant to the provisions of sections 7456 (c)1 of the Code and Rules 180 and 1812 to Special Trial Judge John J. Pajak for purposes of conducting the hearing on petitioner's Motion for Summary Judgment. After a review of the record, we agree with and adopt his opinion which is set forth below.

Opinion of the Special...

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